Contracts and invoices showed that the respondent offered...

Contracts and invoices showed that the respondent offered distinct, itemised services which customers could select independently; applying statutory classification and the bundled-service explanation under the negative-list regime, the tribunal concluded the essential character was transportation (road/rail/GTA) and not Cargo Handling Service, so the activities were not naturally bundled and CHS did not apply. Revenue failed to prove that cargo handling formed the composite's dominant character or that suppression justified extended limitation; amounts already taxed as transport/GTA could not be re-taxed under CHS as that would cause impermissible double taxation. The revenue appeal was dismissed.